In recent years, the Québec Tribunal administratif du travail (the “TAT”) (formerly the Commission des relations du travail) has frequently been called on to address the legal implications involved in the hiring of temporary employees through personnel agencies in the health and social services field.

Most recently, in the case of Professionel (le)s en soins de santé unis (FIQ) and Centre intégré universitaire de santé et services sociaux de l’Est-de-l’Île-de-Montréal[1], the TAT ruled on the issue as to whether nursing and cardio-respiratory professionals who were assigned to the Montréal West Island Integrated University Health and Social Services Centre (the “Centre”) through personnel agencies were included in the Centre’s Professionnel(le)s en soins de santé unis’ bargaining unit (the “Bargaining Unit”), since the union had filed an application under section 39 of the Labour Code, CQLR, c. C-27 to have these professionals included in the said Bargaining Unit.

The union argued that its request was consistent with the principles established by the Supreme Court of Canada (the “Supreme Court”) in Pointe-Claire (City) v Quebec (Labour Court) (“Pointe-Claire”)[2] which promoted a comprehensive and flexible approach to the identification of the “real employer” in a tripartite relationship. In this context, the union emphasised the particular institutional framework of health and social services to support its contention that the true employer was the Centre and not the personnel agencies.

The issue was decided upon on August 25th 2016 by Mr. André Michaud from the TAT, who ruled that in light of the particular institutional framework of health and social services in Québec, the real employer of the temporary employees hired through personnel agencies was the Centre and not the personnel agencies. Hence, the temporary employees were included in the Bargaining Unit.

In reaching this decision, the TAT began its analysis by examining the criteria set forth in Pointe-Claire in order to identify the real employer in the tripartite relationship. The TAT held that the temporary employees assigned by the personnel agencies had to adapt to the strict working conditions of the Centre and were fully integrated into teams of different services or care units. These employees were directly under the control of the Centre. The Court added that the temporary employees had to perform the same tasks, in the same manner and under the same conditions as the permanent employees of the Centre. Furthermore, they were overseen by the same supervisors and used the same equipment in the facilities. From a patient’s perspective, no distinction could be made between both categories of employees. Finally, the TAT underlined that the purpose of using the services of said agencies was not for their nursing expertise but rather for their specific expertise in providing qualified professionals who had such expertise. The Centre communicated very specific requirements with respect to the necessary qualifications and training of the temporary employees and the personnel agencies would in turn find the appropriate candidates. As such, the Centre directly and indirectly controlled almost every aspect of the temporary employees’ hire and working conditions. For all of these reasons, the TAT concluded that the Centre was actually the real employer of the professionals who were assigned to the Centre through personnel agencies.

The implications of the TAT’s findings in this case are highly important because there may be an increase of requests under section 39 of the Labour Code to have all the professionals assigned through personnel agencies included in the employer’s pre-existing bargaining units.

It is worthy to note that this decision is currently undergoing judicial review as both the Centre and personnel agencies argue that the TAT reached its conclusions by misinterpreting the health and social services institutional framework, and without sufficient evidence on the criteria defined by the Supreme Court in Pointe-Claire such as the legal subordination, the selection, discipline and evaluation process as well as the assignment of duties, remuneration and integration into the Centre. We will follow the developments in this important matter with great interest.

The Government of Canada recently completed a consultation with employers, employer associations, union and labour organizations, and advocacy groups as part of its pledge to amend the Canada Labour Code to allow workers in federally regulated sectors to formally request flexible work arrangements from their employers.

What Are Flexible Work Arrangements?

Flexible work arrangements are alternative arrangements to the traditional working week. The most common forms allow an individual employee to alter, on a temporary or permanent basis, his or her work schedule, the number of hours worked or the location where work is done, or to take time off to meet specific responsibilities. Some examples include:

Flexible start and finish times;

The ability to work from home;

Compressed work weeks: working for longer periods of time per day or shift over a defined period of time in exchange for a day off;

Split shifts;

Time swaps: An employee requests time off for personal reasons and offers to make it up by working longer than usual hours on another day; and

Time off in lieu: Overtime can be compensated by time off with pay at the rate of 1.5 hours per overtime hour worked.

According to Employment and Social Development Canada (“ESDC”), flexible work arrangements would help Canadians balance work and family or other personal responsibilities.

Who Will This Affect?

The proposed changes will apply only to federally regulated enterprises which fall under the Canada Labour Code. Some examples include businesses and industries such as banking, marine shipping, ferry and port services, air transportation, railway and road transportation that involves crossing provincial or international borders, telephone and cable systems, radio and television broadcasting, many First Nations activities and most federal Crown corporations. Approximately 11,450 employers and 883,000 workers would be captured by any flexible work rules enacted.

Businesses that follow provincial employment standards legislation would not be affected by the proposed changes. However, these employers are still able to offer flexible work arrangements to their employees provided that the arrangement does not violate provincial employment standards legislation.

No date has been set for when the proposed changes are expected to come into force.

Scope of the Right

ESDC has acknowledged that the proposed changes will not create a right to a flexible work arrangement. Rather, employees would have the right to request a flexible work arrangement. Employers may have legitimate business reasons for denying such a request. Currently however, the grounds for refusing such a request have not yet been set out.

Things to Consider

Flexible work arrangements have potential benefits for employers such as improved employee retention rates, improved productivity, increased job satisfaction, reduced absenteeism and lateness, and being able to schedule work over longer portions of the day.

However, flexible work arrangements may have negative impacts, particularly on the operations of small businesses due to their generally more limited resources to deal with additional administrative burdens. Other concerns raised by employers include potential additional costs, disruptions due to having to reorganize work amongst existing staff, insufficiency of work during the periods the employee proposes to work and problems recruiting additional staff.

The extent to which these potential benefits and drawbacks will affect employers will depend on what changes are made to the Canada Labour Code as well as each employer’s business characteristics.

We will continue to monitor developments to the government’s proposal and provide updates as more information about the proposed changes to the Canada Labour Code become known.

In a recent grievance decision, Re Prince George and Prince George Firefighters, Local 1372 (Williams), 2016 CarswellBC 2591, a labour arbitrator reinstated a firefighter whose employment was terminated after being found guilty of possession of a stolen boat and trailer.

The arbitrator concluded that in order to justify terminating a unionized employee, there must be a sufficient nexus between the employee’s misconduct away from work, and his employment duties.

Facts

The Grievor had been a firefighter for 11 years with a pristine work record. There were no concerns with his honesty or work. In 2012, he purchased a boat and trailer for $9,500 from a fellow firefighter. The boat, reportedly worth approximately $30,000, had been stolen. The state of the Grievor’s knowledge when he purchased the boat was disputed.

The Grievor was arrested in 2013. The RCMP phoned the Grievor and asked to attend his property to investigate a tip that a stolen boat was located on his property. Within minutes of the call, the Grievor hooked the boat and trailer up to his car and began towing it away from his property. However, the Grievor’s property was under surveillance and he was arrested.

The Grievor lied about his acquisition of the boat and trailer in his initial statement to police, providing a story about how he purchased the boat, and three different purchase prices. He later admitted to the RCMP that he bought the boat from a fellow firefighter for much less, but he did not admit to knowing the boat was stolen. However, he made some comments that he had doubts about the deal, and suggested he “had an inkling in the pit of his stomach” about it.

The employer investigated and the Grievor reluctantly admitted to the arrest. The Grievor was placed on leave, but the employer did not initially ask if he knew the boat was stolen. When asked in a subsequent interview, the Grievor said it was a “grey area”. He also advised the employer of his attempt to flee with the boat. The employer allowed the Grievor to return to work with conditions, accepting that he was being forthright.

In the criminal proceedings, the court did not accept the Grievor’s evidence, and he was found to have known the boat was stolen. The trial was widely reported in the local media.

Upon learning of the verdict, the employer terminated the Grievor’s employment. The employer’s reasons, as stated at arbitration, included: the comments made by the judge regarding the non-acceptance of the Grievor’s evidence and his credibility, dishonesty and lack of judgment; the media reports and negative publicity; and concerns about the Grievor’s honesty during the employer’s investigation.

Arbitrator’s Reasons

The arbitrator found it difficult to reconcile evidence regarding the Grievor’s police statement and his evidence at trial and arbitration that he had no concern the boat was stolen. She noted that she had “grave doubts” as to his understanding of the underlying issue of his honesty. Nevertheless, she proceeded to consider the question of whether termination was excessive in the circumstances.

To this end, relying on Millhaven Fibres Ltd. and OCAW, Local 9-670, Re, [1967] O.L.A.A. No. 4 (Ont Arb), the arbitrator noted that in determining whether the Grievor’s conduct away from the place of work was a justifiable reason for discharge, there was an onus on the employer to show that:

The conduct of the Grievor harms the employer’s reputation or product;

The Grievor’s behaviour renders the employee unable to perform his duties satisfactorily;

The Grievor’s behaviour leads to refusal, reluctance or inability of the other employees to work with him;

The Grievor has been guilty of a serious breach of the criminal code and thus rendering his conduct injurious to the general reputation of the employer and its employees;

The conduct causes difficulty in the way the employer properly carries out its function of efficiently managing its works and efficiently directing its working force.

The arbitrator found there was no direct link between the misconduct and the Grievor’s duties. There was no suggestion he could not be trusted to do his firefighting duties. The arbitrator accepted that it was an isolated incident by an employee with a pristine work record, not likely to be repeated. Moreover, he was not in a fiduciary position, and his duties did not expose him to the temptation of greed.

In short, the arbitrator concluded that there was an insufficient nexus between the Grievor’s misconduct and his duties to warrant termination. Accordingly, the arbitrator reinstated the Grievor, but declined to award wages, seniority or benefits from the date of termination to the date of reinstatement.

Take Away

Criminal convictions in and of themselves may not justify termination of an employee on the basis of dishonesty and lack of trust. Despite findings of misconduct in criminal proceedings, employers terminating for cause must establish that the misconduct actually relates in more than a general manner to the duties to be performed by the employee.

Alberta employers are reminded that the general minimum wage in Alberta will be increased on October 1, 2016 to $12.20 per hour, up from $11.20 per hour. Additionally, the current liquor server rate will be eliminated effective October 1, 2016 and these employees will also now earn the general minimum wage. Employers are reminded to update their employment contracts and practices to ensure they reflect the new minimum wage.

The minimum wage will increase a further $1.40 to $13.60 per hour on October 1, 2017, and by $1.40 to $15.00 per hour on October 1, 2018.

Technological developments and the need for employers to monitor employees’ activities and to minimize accidents and hazards require constant adjustments in order to respect the right to privacy. While it may be tempting for employers to replace old surveillance methods with new technologies capable of watching their personnel’s every move, the inclination to use easier and more reliable ways of supervising employees must nonetheless not violate employees’ right to privacy, which, while being more limited in a work context, nevertheless exists.

In a recent Quebec arbitration ruling, Sysco, a food delivery company, had decided to install a DriveCam® safety program inside the drivers’ cabins of its trucks in Quebec. The Union disagreed with the introduction of this new surveillance measure and filed a grievance to have said cameras removed, alleging that they were not only violating the truck drivers’ rights to privacy and dignity, but that they were also leading to unfair and unreasonable working conditions. In addition, the Union claimed that Sysco had failed to establish serious motives which would justify its resort to the use of such invasive surveillance, especially considering the existence of a no‑fault system in Quebec. On its end, Sysco claimed that it was justified to install the cameras as they were meant to (i) be used as a training tool for the drivers, (ii) increase and encourage safe driving and (iii) assist with liability determination or exoneration in case of accident.

In ruling that Sysco was not justified in installing those cameras and ordering that they be removed, the Arbitrator used a two-fold analysis. First, did Sysco have a specific problem that needed to be addressed with these cameras? Second, were these cameras the only way to fix the alleged problem, or was there a less intrusive way to achieve similar results?

On the first part of the analysis, the Arbitrator found that Sysco had failed to establish that it had an existing problematic situation that needed to be fixed. The employer’s concern for prevention regarding safe driving and liability determination or exoneration did not constitute strong motives for which the surveillance would be warranted. Considerable risks revealing an existing problem would have been enough to establish the presence of a problem, but Sysco had not established such a problem. For example, a widespread problem having to do with alcohol or drug consumption during working hours would have constituted a great risk in the matter of safe driving.

With respect to the second aspect of the analysis, Sysco’s concern could easily have been addressed by other less intrusive means, such as training, random safety spot-checks, or cameras installed outside of the trucks rather than inside the cabins. In fact, cameras constantly filming the drivers inside the trucks’ cabins had even proven to be distracting for the drivers, thus potentially creating a greater risk from a safety perspective.

Employers who may be tempted to install such surveillance systems on their fleet will need to remember that any such violation of their employees’ right to privacy will only be justified by identifying an existing specific problem that cannot be fixed by a less intrusive means than the surveillance system the employer wishes to install.

In a decision which returns us to what many thought was the status quo, the Supreme Court of Canada has ruled that, (save for exempt employees), the unjust dismissal scheme in the Canada Labour Code (the “Code”) does not permit federally regulated employers to dismiss employees without cause once they have one year of service or more. This decision reverses the decisions of the Federal Court and Federal Court of Appeal, which had ruled that nothing in the Code precluded federally regulated employers from dismissing non-unionized employees on a without cause basis. As a result, for federally regulated employers, when it comes to dismissal, the right of non-union employees to protection from dismissal tracks the right of their unionized counterparts.

Facts:

In November 2009, Atomic Energy Canada Limited (“AECL”) dismissed a procurement supervisor after four and a half years of service. The employee promptly filed an “Unjust Dismissal” complaint, claiming that he had been unjustly dismissed contrary to the Code. In response, AECL argued that because it had provided the employee with a generous severance package well in excess of his minimum statutory entitlements (i.e. 6 months’ pay), the employee had not been unjustly dismissed. The Adjudicator appointed to hear the matter disagreed with AECL and ruled that an employer could not rely on severance payments, however generous, to avoid a finding that an employee had been unjustly dismissed under the Code.

In a surprise to many, the Federal Court of Canada, and then the Federal Court of Appeal, disagreed with the Adjudicator, holding that nothing in the Code prevented federally regulated employers from dismissing non-unionized employees without cause. The employee appealed to the Supreme Court of Canada.

Supreme Court of Canada:

Writing for the majority, Justice Abella stated that the purpose of the Code’s unjust dismissal scheme was to provide “…a cost-effective alternative to the civil court system for dismissed employees to obtain meaningful remedies which are far more expansive than those available at common law”. In Justice Abella’s view, the remedies contemplated by the Code for non-unionized employees were meant to reflect those generally available in the collective bargaining context. As such, in the federal sphere, the common law right of employers to dismiss “…whomever they want for whatever reason they want so long as they give reasonable notice or pay in lieu” was superseded by the Code, which did not give federally regulated employers such a right.

What this means for Federally Regulated Employers:

For better or for worse, the Supreme Court of Canada’s decision provides legal certainty for Canada’s federally regulated employers, as it ends the debate about whether the Code permits without cause dismissals. That said, the Supreme Court of Canada’s decision does not mean that an employee’s right to sue his or her former employer in court for wrongful dismissal has been extinguished. As the minority noted in this case, due to a legislative wrinkle, a federally regulated employer can dismiss an employee without cause as long as that employee chooses to challenge the lawfulness of the dismissal in the civil courts. However, if the employee files a complaint under the Code’s unjust dismissal scheme, the notice provided to the employee will not insulate the employer from an adjudicator’s finding that the dismissal was nonetheless unjust.

Accordingly, unless and until the Code’s unjust dismissal scheme is amended to allow for without cause dismissals, federally regulated employers can only dismiss an employee with one year of service or more due to performance issues, a lack of work or the discontinuance of a function. Failure to meet this requirement could result in significant liability for the employer, including reinstatement.

In light of the Saskatchewan Federation of Labour v Saskatchewan, 2015 SCC 4 decision, the Alberta government has undertaken a review of the Labour Relations Code (“LRC”) and the Public Service Employees Relations Act (“PSERA”). Following a consultation with affected employers, unions and employees, on March 15, 2016 the Alberta government introduced Bill 4, An Act to Implement a Supreme Court Ruling Governing Essential Services (“Bill 4”).

Prior to the amendments, public sector employees governed by PSERA and the LRC could not strike. The new legislation, colloquially known as the essential services legislation, allows for strikes and lockouts of public sector employees who could not previously strike. This includes health care workers employed by Alberta Health Services and other approved hospitals, employees of the provincial government and agencies, boards and commissions and non-academic staff at post-secondary institutions. The amendments do not impact firefighters, non-Alberta Health Services ambulance operators and their attendants, police officers, academic staff and graduate students at post-secondary institutions.[1]

The amendments will allow employees to strike while still maintaining essential services. In order to maintain essential services, the employer and the employees’ union will negotiate essential services agreements. The amendments require the negotiations to be in good faith and make every reasonable effort to enter into an essential services agreement. The following must be included in all essential services agreements:

provisions that identify the essential services that are to be maintained by employees in the bargaining unit in the event of a strike or lockout;

provisions that set out the classifications of employees, and the number of positions in each classification, required to perform the essential services referred to in clause (a);

provisions that set out a method by which the employees capable of performing and qualified to perform essential services will be assigned to perform those services during a strike or lockout;

provisions that set out the procedures to be followed in responding to emergencies and foreseeable changes to the essential services that need to be maintained during a strike or lockout;

provisions describing changes or permitted changes, if any, to the terms and conditions of employment that are to apply to designated essential services workers under sections 130(2) and 147(4) of the Act and sections 24.1(2) and 46(2.1) of the PSERA;

provisions that identify sufficient umpires, but at least one umpire, to be available to provide timely resolution of disputes under section 95.7; and

any other provisions specified in the regulations.

Should parties be unable to agree on the contents of an essential services agreement, they may agree to use an umpire to mediate and, if necessary, may seek guidance from the Commissioner (the individual who oversees the administration of the essential services legislation, as defined in the legislation), to assist with settling the essential services agreement.

Once an essential services agreement is reached, it must be filed for each round of collective bargaining. The parties must also declare to the Commissioner: (a) whether the agreement ensures that essential services are maintained during any strike or lockout; and (b) whether the provision of essential services required by the essential services agreement during a strike or lockout will substantially interfere with meaningful collective bargaining. The Commissioner has several options should an essential services agreement be unacceptable, including making unilateral amendments to the agreement.

An essential services agreement accepted for filing is binding on: (a) the employer; (b) the bargaining agent; and (c) every employee of the employer who is in the bargaining unit represented by the bargaining agent.

Bill 4 has since undergone its second reading and amendments during the Committee of the Whole and on April 16, 2016, the Bill passed its third reading in the legislature. Bill 4 is currently waiting Royal Assent. The deadline to amend the legislation was extended to the end of the spring 2016 sitting of the Alberta Legislature.

Once given Royal Assent and the amendments have come into force, a number of public sector employees will now have the right to strike with only essential services designated workers being prohibited to do such.

[1] However, the Post-secondary Learning Act is currently under review.

An arbitrator recently upheld the termination of a “reliable and capable” Personal Support Worker (a “PSW”) with no prior disciplinary record, because of significant mistreatment of an individual she was responsible for, and because she did not show the kind of insight required.

The Grievor had 6 years of service as a PSW in a licensed long-term care home (the “Home”). Her most recent performance appraisal showed perfect attendance and an overall rating of 41 out of 48 for the relevant review period. She was nominated for the “2013 Face of Safety Award”, but by May 2013 she had become the face of the villain in a video that was widely circulated in the media.

The Home served vulnerable residents living with significant physical, psychological and/or behavioural impairments. The Grievor’s role as a PSW involved assisting residents with their activities of daily living (ADL), often alone and unsupervised. The resident at the centre of this grievance was an 85-year old woman living with Alzheimer’s (the “Resident”).

The Grievor claimed that on the day of the incident that culminated in her termination, smells emanating from the Resident’s room alerted her to the fact that the Resident needed to be cleaned and changed. She testified that although the Resident resisted care, she persisted out of concern for the Resident’s comfort and her fear that the Resident might develop sores if left unattended in the “pool of urine and feces”. The Grievor also testified that because the Resident was resisting care, she showed the Resident the soiled washcloth to prove to her that she needed care.

The 7-minute montage from a hidden camera that the Resident’s son had placed in the room, and later shared with the media, told a different story. The Resident was seen lying contentedly on her bed until the Grievor attempted to get her out of bed. As the Resident resisted, the Grievor pulled the Resident, grabbed her by her neck and tried to lift her out of bed. The next few minutes were not captured by the camera, as the Grievor and the Resident moved to the bathroom. After they returned the Resident lay on the bed without protest, rolled onto her side without protest and appeared totally compliant. The Grievor then waved the feces-covered cloth in the Resident’s face. As a result the Resident became agitated and began to refuse care. The Grievor persisted in delivering care and roughly pushed the Resident and rolled her around. At no point in the video did the arbitrator see any soiled bedding or any “pool of urine and feces”.

The Home alleged that the Grievor’s conduct constituted abuse, breached the Resident’s Bill of Rights under the Long-Term Care Homes Act, 2007 and breached several organizational and generally accepted protocols.‎

The Home led evidence that given the Resident’s frailty and the manifestations of Alzheimer’s, it was critical that the Grievor comply with the protocols the Home had developed for dealing with resistance. Instead, the Grievor began by ignoring the two-person lifting and transferring protocol. She also ignored the universally accepted “leave and reapproach” method. When the Resident refused care, instead of persisting, the Grievor should have left, waited a few minutes and then reapproached with the assistance of another employee. The Home maintained that the Grievor’s conduct was a significant breach of trust requiring not just discipline, but termination.

The arbitrator agreed. He said the Grievor demonstrated a “fundamental lack of judgement”, falling within the definition of abuse and going to the heart of the employment relationship. He also acknowledged that long-term care employees like the Grievor held positions of public trust and public interest, which demanded a very high standard of conduct.

The arbitrator commented that reinstatement would have been very likely if he had found that the Grievor had accepted full responsibility and provided him with confidence that she would not repeat her conduct. Moreover, if he had accepted her explanation as being credible and consistent with the video he would have seriously considered reinstatement. Instead, the arbitrator concluded that the Grievor did not seem to grasp that in future she should use the “leave and reapproach” method. Although the Grievor apologized and declared her willingness to undergo counselling and do whatever was required to repair the employment relationship, this was, in the eyes of the arbitrator, not enough to give him the confidence that would make reinstatement appropriate.

The Grievor’s ideal response would have been one that satisfactorily explained her conduct, demonstrated insight, and above all, instilled confidence she would never repeat her conduct. An earnest response would not have “downplayed her culpability”.

On one level this case is a reminder that grievances can turn on the ability to adduce evidence or elicit testimony about the likelihood that an employee will re-offend. Beyond that, this is an important reminder of the value of effective recruitment and selection processes. Employers should design recruitment and selection processes to identify candidates who likely possess the insight to appreciate and apply the policies and training that are provided to help them deal with difficult situations.

Federally regulated employers take note. The Federal Court of Appeal has recently confirmed that without cause dismissals are not automatically deemed to be “unjust” under the provisions of the Canada Labour Code (the “Code”).

For decades, adjudicators have been at odds with one another regarding the question of whether the Code permits dismissals on a without cause basis. As a matter of background, the Code applies only to federally regulated employers such as banks, railways and telecoms. After years of uncertainty in this area, the Federal Court of Appeal recently decided to end the discord and definitively determine the legal point.

In the case of Wilson v. Atomic Energy of Canada Limited, Mr. Wilson was employed for 4.5 years before being terminated on a without cause basis and offered a common law package equal to about 6 months of pay. Mr. Wilson chose not to sign a release in exchange for the offer and instead filed a complaint under the Code which alleged that he had been unjustly dismissed.

After both an adjudication and a Federal Court hearing, the matter proceeded to the Federal Court of Appeal, which found that a dismissal without cause is not automatically “unjust” under the Code and that adjudicators must examine the circumstances of each particular case in order to decide whether or not a dismissal is unjust. In its analysis, the court determined that Part III of the Code (which contains exceptional remedies such as reinstatement of employment) is merely intended to offer employees more remedies than exist under the common law, but only if the dismissal is unjust. The extra remedies granted under Part III do not, however, mean that all without cause dismissals under the Code are automatically unjust.

As a result, federally regulated employees who are terminated without cause must prove that they have been terminated unjustly if they want that conclusion to be drawn. In practical terms, this means that where there is no finding of unjust dismissal, a federally regulated employee can be terminated without cause and simply provided with a notice or severance package. In order to gain the benefit of Code remedies which do not exist under the common law, such as the right to reinstatement, the employee must go the extra step and establish that the without cause termination was “unjust”.

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